What question did this study set out to answer?

To explore the introduction and impact of the UAE advance pricing agreement programme on transfer pricing.

May 13, 2026

Upfront Transfer Pricing Certainty and Compliance via Advance Pricing Agreements in the United Arab Emirates

MMMalcolm Manekshaw DRDion de Ruijter AMAlina Minea

Key Points

To explore the introduction and impact of the UAE advance pricing agreement programme on transfer pricing.
Examine the legal framework of APAs in the UAE.
Outline the eligibility criteria for participating in the APA programme.
Discuss the negotiation process for APAs.
Identifies types of related-party transactions that can benefit from APAs.
Assesses the UAE APA regime's alignment with global standards.
Highlights the potential for improved transfer pricing compliance.

Abstract

This article examines the introduction of the United Arab Emirates (UAE) advance pricing agreement (APA) programme, outlining its legal framework, eligibility criteria and negotiation process. It highlights the types of related-party transactions most likely to benefit from APAs and situates the UAE regime within the context of established global APA programmes, assessing its role in enhancing transfer pricing certainty and compliance.

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